I. Name and address of the controller responsible for data processing and of the data protection officer
The controller responsible for data processing within the meaning of the General Data Protection Regulation (GDPR), other EU member state data protection laws and further data protection regulations is
You can contact the Actions data protection officer at
II. Data processing
1. General information
We collect and process our usersʼ personal data only to the extent necessary to ensure the proper working of our website and to deliver our content and services. We process our usersʼ personal data only after they have consented to such processing. An exception is made in those cases in which it is not possible, for practical reasons, to obtain prior consent and the processing of such data is permissible by law. ‟Personal data” means all those data relating to you personally, for example your name, postal address, email address and user behaviour.
Each time you access our website, our system automatically collects data and information from the accessing deviceʼs system. The following data are stored:
(1) The internet service providerʼs IP address;
(2) The date and time of access;
(3) The name of the file accessed and the data volume transferred;
(4) Notification of whether the action was successful or not.
Point (f) of Article 6(1) of the GDPR forms the legal basis for the above.
The IP address needs to be temporarily stored to enable the website to be delivered to the userʼs device. That is why the userʼs IP address needs to be stored for the duration of the session.
You have the option of contacting us by email. Personal data are only collected if you voluntarily notify us of these data in your email. In such cases we will store the personal data transmitted to us so that we can process and respond to your request. These data are not passed on to third parties.
Point (a) of Article 6(1) of the GDPR forms the legal basis for the above.
Processing of your personal data enables us to deal with your request.
You may, at any time, withdraw your consent to personal data being stored. The email conversation will, however, then be discontinued. You can withdraw your consent by writing to the controller responsible for data processing either by post or email (see I. above for contact details).
III. Retention period
A data subjectʼs personal data are erased or blocked as soon as the purpose of storage no longer applies. Personal data may, further, be stored where provided for by either the European or national legislature in Union regulations, laws or other directives to which the controller is subject. Data are also blocked or erased once the retention period provided for in the relevant data protection norms expires.
Data stored for the purpose of data processing are erased as soon as they are no longer needed to achieve the purpose for which they were collected. Those data which are recorded for the purpose of delivering our website are deleted once the session ends.
IV. Rights of data subject
Where personal data relating to you are processed, then you are the ‟data subject” within the meaning of the GDPR. In accordance with Article 15 et seqq. of the GDPR, you thus have the following rights vis-à-vis the controller:
1. Right of access
You have the right to obtain confirmation from the controller as to whether or not we are processing personal data relating to you. Where this is the case, you have the right to access to the personal data and to the following information:
(1) The purposes for which your personal data are being processed;
(2) The categories of personal data which are being processed;
(3) The recipients or categories of recipients to whom your personal data have been or will be disclosed;
(4) The envisaged period for which your personal data will be stored, or, if provision of this information is not possible, the criteria used to determine that period;
(5) The existence of the right to request correction or erasure of your personal data or restriction of the processing of personal data by the controller, or to object to such processing;
(6) The right to lodge a complaint with a supervisory authority;
(7) Where the personal data are not collected from the data subject, any available information as to their source;
(8) The existence of automated decision-making, including profiling, as defined in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processes for the data subject.
You have the right to information about whether your personal data are being transmitted to a third country or to an international organisation. Where this is the case, you have the right to be informed about appropriate safeguards as set out in Article 46 of the GDPR relating to the transfer.
2. Right to rectification
You have the right to obtain from the controller the rectification and/or completion of inaccurate or incomplete personal data concerning you. The controller must rectify such data immediately.
3. Right to restriction of processing
You have the right to obtain restriction of the processing of your personal data where one of the following conditions applies:
(1) You contest the accuracy of the personal data relating to you for a period which enables the controller to verify the accuracy of the personal data;
(2) The processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
(3) The controller no longer needs the personal data for the purposes of the processing but you require them for the establishment, exercise or defence of legal claims;
(4) If you object to the processing in accordance with Article 21(1) of the GDPR and it is not yet clear whether the legitimate grounds of the controller override your grounds.
Where processing of your personal data has been restricted, these personal data may, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the EU or of a member state.
Where processing has been restricted under one of the above conditions, you will be informed by the controller before the restriction is lifted.
4. Right to object
You have the right, on grounds relating to your particular situation, at any time to object to the processing of personal data relating to you which is based on point (e) or point (f) of Article 6(1) of the GDPR; this also applies to profiling based on those provisions.
The controller will no longer process your personal data unless compelling legitimate grounds for the processing can be demonstrated which override your interests, rights and freedoms or the processing serves the establishment, exercise or defence of legal claims.
In the context of using information society services and notwithstanding Directive 2002/58/EC, you may exercise your right to object to automated means using technical specifications.
5. Right of erasure
5.1. Obligation to erase data
You have the right to obtain from the controller the immediate erasure of personal data concerning you. The controller is obliged immediately to erase these data where one of the following grounds applies:
(1) The personal data concerning you are no longer required for the purposes for which they were collected or otherwise processed;
(2) You withdraw the consent on which the processing is based as set out in point (a) of Article 6(1) or point (a) of Article 9(2) of the GDPR, or there is no other legal ground for the processing;
(3) You object to the processing in accordance with Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing as set out in Article 21(2) of the GDPR;
(4) The personal data concerning you have been unlawfully processed;
(5) The personal data concerning you have been erased to satisfy a legal obligation under EU or member state law to which the controller is subject;
(6) The personal data concerning you have been collected in relation to the offer of information society services as set out in Article 8(1) of the GDPR.
5.2. Notification to third parties
If the controller has made your personal data public and is obliged, in accordance with Article 17(1) of the GDPR, to erase them, then the controller, taking account of available technology and the cost of implementation, must take reasonable steps, including technical measures, to inform controllers processing the personal data that you, the data subject, have requested such controllers to erase any links to or copies or replications of those personal data.
The right to erasure does not apply where the processing is necessary
(1) to exercise the right of freedom of expression and information;
(2) to satisfy a legal obligation which requires processing under EU or member state law to which the controller is subject or to perform a task carried out in the public interest or exercise official authority vested in the controller;
(3) for reasons of public interest in the area of public health as set out in point (h) and point (i) of Article 9(2) and in Article 9(3) of the GDPR;
(4) for archiving purposes which are in the public interest, scientific or historical research or for statistical purposes as set out in Article 89(1) of the GDPR in so far as the right referred to in 5.1 above is likely to render impossible or seriously impair the achievement of the objectives of that processing;
(5) for the establishment, exercise or defence of legal claims.
6. Right to notification
Where you have asserted your right to rectification, erasure or restriction of processing vis-à-vis the controller, the controller is obliged to notify each recipient to whom your personal data have been disclosed, unless this proves impossible or involves disproportionate effort. You have the right to be notified by the controller about who these recipients are.
7. Right to data portability
You have the right to receive, in a structured, commonly used and machine-readable form, the personal data concerning you which you have provided to the controller. You also have the right to transmit these data to another controller without hindrance from the controller to whom the personal data were originally provided, where
(1) the processing is based on consent as defined in point (a) of Article 6(1) or point (a) of Article 9(2) of the GDPR or on a contract as referred to in point (b) of Article 6(1) of the GDPR; and
(2) the processing is carried out by automated means.
Further, in exercising this right to data portability you have the right to have your personal data transmitted directly from one controller to another, where this is technically feasible. The rights and freedoms of other persons may not be adversely affected by such transmission.
The right to data portability does not apply to the processing of personal data which is necessary to perform a task carried out in the public interest or in the exercise of official authority vested in the controller.
8. Right to lodge a complaint with a supervisory authority
Irrespective of other administrative or judicial legal remedies, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence or place of work or of the place of the alleged infringement if you are of the opinion that the processing of personal data relating to you infringes the GDPR.
The supervisory authority with which the complaint has been lodged informs the complainant on the progress and the outcome of the complaint, including the possibility of a judicial remedy as referred to in Article 78 of the GDPR.
9. Right to withdraw consent
You have the right at any time to withdraw your consent to the processing of your personal data. The withdrawal of consent does not affect the lawfulness of any processing based on consent before its withdrawal.